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Back to Main Page ... Lead Renovation, Repair and Painting (RRP) Rule

RRP Rule:  Pre-Renovation Education Requirements

Under the RRP Rule, contractors, property managers, and others who perform renovations for compensation in residential houses, apartments, and child-occupied facilities built before 1978 are required to distribute a Renovate Right pamphlet to the owner and occupants before starting renovation work.  The Renovate Right pamphlet is available in English and Spanish--choose the language best suited for the building occupants.

The following summarizes pre-renovation education requirements.  Note that states or tribes may impose additional requirements.

In housing built before 1978, you must:

In a child-occupied facility, you must:

  • Distribute EPA’s Renovate Right pamphlet to the owner of the building or an adult representative of the child-occupied facility before the renovation starts.
  • Either distribute renovation notices to parents/guardians of the children attending the child-occupied facility or post informational signs about the renovation or repair job.

For work in common areas of multi-family housing, you must:

Informational signs must: 

  • Be posted where they will be seen; 
  • Describe the nature, locations, and dates of the renovation; and 
  • Be accompanied by the EPA’s Renovate Right pamphlet or by information on how parents and guardians can get a free copy.

Obtain confirmation of receipt of EPA’s Renovate Right pamphlet from the owner, adult representative, or occupants (as applicable), or a certificate of mailing from the post office.  

The acknowledgements must be written in the same language as the contract or agreement for the renovation or, in the case of rental housing, in the same language as the lease or rental agreement.  Find a sample pre-renovation confirmation form to acknowledge receipt of notice to residents at https://www.epa.gov/lead/sample-pre-renovation-form-confirmation-receipt-lead-pamphlet. 

Be Sure to Keep Records of your Work

You will need to keep documents showing how you complied with the requirements of the RRP Rule.  You must keep all documents for three years following the completion of a renovation.  And you will be required to provide a certified checklist showing your work to the owner and occupants.  See the Recordkeeping page for more details and tips.

Note: Pre-renovation education requirements do not apply to emergency renovations, i.e., situations requiring immediate action to address safety or public health hazards or threats of significant damage to equipment and/or property.  For example, fixing a burst water pipe could be considered an emergency renovation, but fixing the drywall and painting would not be.  Emergency renovations include interim controls performed in response to a resident child with an elevated blood-lead level.  The cleaning, cleaning verification, and recordkeeping requirements of the RRP Rule still apply even for an emergency renovation.

You can find the regulatory language for the RRP Rule Pre-renovation education requirements at 40 CFR 745.84.

 

Back to Main Page ... Lead Renovation, Repair and Painting (RRP) Rule